[arin-ppml] A Redefinition of IPv4 Need post ARIN run-out (was:Re:Against 2013-4)

[Steven Ryerse]

Don't know if a /12 cap would work if a big guy like tmobile or Microsoft applied for a larger allocation. It is fine for most organizations though. 

Sent from my iPhone

On Jun 12, 2013, at 10:21 AM, "Mike Burns" <mike at iptrading.com> wrote:

> Hi Steve, Bill, Brandon,
> 
> Thanks for your input.
> Yes, I should have been clearer in that the original proposal called for a /12 per year per organization cap.
> 
> At least at this point in time, the number of transfers is relatively low, the block sizes also, and  I think the staff at the RIRs would certainly detect attempts to evade the needs test through transfers to linked shell corporations.  When the block sizes and values get big (/12, $10million), the number of players willing to risk borderline fraud gets small, in my opinion. With ARIN staff freed from processing justifications, perhaps they will have more time to devote to detecting this kind of activity.
> 
> As for the cap size being based not on annual transfers, but instead on aggregate block size of the receiving entity, I think it worthy of consideration. It seems like the effect will be to allow most transfer transactions to proceed without needs tests.  Do we think that this form of cap will have the same effect on the protection against hoarding and price manipulation?
> 
> Regards,
> Mike
> 
> 
> 
> 
> 
> 
> -----Original Message----- From: Steven Ryerse
> Sent: Wednesday, June 12, 2013 7:23 AM
> To: Brandon Ross ; William Herrin
> Cc: Mike Burns ; ARIN PPML
> Subject: RE: [arin-ppml] A Redefinition of IPv4 Need post ARIN run-out (was:Re:Against 2013-4)
> 
> Brandon and Bill, I think you are on the right track.  I've said recently that allocations of IPv4 should be limited to some combination of organization size and/or current IP allocations.  Of course translating that into a policy that works is tricky but doable I think.  Why not take the needs test completely off the "Minimum Allocation Size" which I think is currently a /22.  Add a standard waiting period between allocations of say 6 months.  Provide some way an organization with a hardship can apply sooner than 6 months if they have a truly demonstrable need.  Then match the allocation request size with the organizations current allocation's - and/or their current network size or financial size.
> 
> On the low end some more /22 allocations really aren't going to cause exhaustion that much faster and on the large size all the way to a /8, only organizations who are big enough would get a big allocation similar to the way T-Mobile got 3/4 of a /8 a while back.  If a big guy like an AT&T or Verizon  were to apply for a /8, even though ARIN only has one full /8 left, I'm guessing they could justify it under almost any needs criteria or they wouldn't be requesting it.  I'm sure this community has the knowhow to come up with policies that accomplish this.
> 
> Under this scenario the needs part of the allocation request is removed and what remains is a rightsizing policy in its place to reduce hoarding as best as we can.  My gut tells me that changing to this kind of allocation process would not cause ARIN to run out of addresses much sooner than current policies.
> 
> -----Original Message-----
> From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf Of Brandon Ross
> Sent: Wednesday, June 12, 2013 12:07 AM
> To: William Herrin
> Cc: Mike Burns; ARIN PPML
> Subject: Re: [arin-ppml] A Redefinition of IPv4 Need post ARIN run-out (was:Re:Against 2013-4)
> 
> On Tue, 11 Jun 2013, William Herrin wrote:
> 
>> On Tue, Jun 11, 2013 at 9:22 PM, Mike Burns <mike at nationwideinc.com> wrote:
>>> What about a needs-free transfer cap?
>> 
>> It'd have to be per-timeframe (per year). A per-transfer cap would be
>> meaningless.
> 
> I support the idea, in general, of needs-free transfer cap, however, I'd suggest that cap be based on the total amount of address space that an entity controls rather than a per period or per transfer based cap.
> 
> In other words, if you are big enough to justify, in total, a /12 of address space, then you are big enough to handle the burden of justification.  If you have less space than that, in aggregate, then the needs requirement can be waived.
> 
> If shell corporations are a concern, then the cap can be made small enough such that any attempt to corner the market would be easy to detect because of the sheer number of shells necessary to do so.  Perhaps it's possible to hide the ownership of a dozen, but certainly not 100 or 1000.
> 
> It is worthwhile, however, to point out that if I wanted to hoard IPv4 address space, there's nothing stopping me from doing that using shell corporations now, so I don't see how removing the cap for small allocations really makes much of a difference.
> 
> -- 
> Brandon Ross                                      Yahoo & AIM:  BrandonNRoss
> +1-404-635-6667                                                ICQ:  2269442
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